The Roadless Rule is under attack again: Your guide to the new 2026 public comment period
If you followed me last year, you probably remember hearing a LOT about the Roadless Rule and our opportunity to have our voices heard through the official comment period.
Well, we’re back.
The Trump administration has taken the next major step toward repealing one of the most important conservation policies in the country. The USDA officially published its proposed rule to rescind the 2001 Roadless Rule, along with a massive Draft Environmental Impact Statement (DEIS), looking at what could happen if those protections are removed.
That means we have another public comment period, but this one is a little different from the one we participated in last year.
Last year, the USDA asked the public what it should study as part of the environmental review. We raised concerns, pointed them toward research, identified places and communities that could be impacted, and asked them to consider alternatives. More than 220,000 comment letters were received (625,000 individual submissions), and 99% of those were opposed to the Roadless Rule rescission.
Now the DEIS is out. We can actually see what the agency studied, what conclusions it reached, what it left out, what it downplayed, and where its own analysis raises more questions than answers. To nobody’s surprise, much of the content of the DEIS contradicts what they’re proposing in the Roadless Rule rescission (referred to as Alternative 1).
Comments are due September 21, 2026.
TL;DR
The Trump administration is proposing to fully rescind the 2001 Roadless Rule, which currently protects about 44.7 million acres of National Forest land from most new road construction, road reconstruction, and timber harvest.
This is a new comment period focused specifically on the DEIS and proposed rule. Last year’s comment period was about what the Forest Service should study; this one is about responding to what it actually analyzed.
The USDA is proposing a full rescission of the Roadless Rule, removing protections from about millions of acres of land.
The Forest Service’s own analysis identifies major concerns under full rescission, including impacts to wildlife, drinking water, recreation, Tribal rights, road-maintenance costs, and wildfire risk.
Comments are due September 21, 2026. Tell the USDA to reject Alternative 2 and choose Alternative 1, the No Action Alternative.
What’s happening right now? A timeline of the Roadless Rule
Roadless Rule timeline
On June 23, 2025, USDA Secretary Brooke Rollins publicly announced the administration’s intention to rescind the 2001 Roadless Rule. (Draft EIS Volume I, p. 8.)
Then, on August 29, 2025, USDA published a Notice of Intent announcing that it would prepare an Environmental Impact Statement evaluating the proposal. That kicked off a 21-day public comment period.
On Aug. 20, 2026, the USDA released its official DEIS and proposed ruling, opening up another public comment period ending September 21, 2026.
During the last comment period in 2025, there was no Draft Environmental Impact Statement (DEIS) yet. The public was being asked to weigh in on what the Forest Service should analyze, what impacts it should consider, what alternatives it should study, and what research or information should be part of the record.
A lot of people showed up.
The USDA received more than 220,000 comment letters during that period. Counting petition signatures individually, those letters represented more than 625,000 submissions. The DEIS also says approximately 99% of the letters were generally opposed to rescinding the Roadless Rule, while approximately 1% were generally supportive. (Draft EIS Volume I, p. 9.)
The USDA says those comments helped inform the alternatives and environmental analysis. According to the DEIS, the agency clarified the proposed action, analyzed an additional alternative, incorporated information and literature submitted through comments, and made corrections or updates to the document.
Now the DEIS is public, so the questions are much more specific.
Does the analysis make sense? Did the agency fully account for the impacts it identified? Are there contradictions between the stated reasons for rescission and the agency’s own findings? Were reasonable alternatives dismissed too quickly? Are the impacts to wildlife, water, recreation, Tribal rights, and public lands being adequately weighed?
That is what this comment period is about.
What exactly is USDA proposing?
The DEIS looks at three alternatives. You can read about them more in-depth in the documents directly, but here’s a quick summary. The administration is proposing Alternative 2, full rescission.
Alternative 1: No Action (this is what we want)
This keeps the 2001 Roadless Rule in place.
Under this alternative, the existing restrictions on road construction, road reconstruction, and timber harvest would continue across approximately 44.7 million acres of inventoried roadless areas covered by the national rule. The rule would also keep its existing exceptions for public health and safety, certain reserved or outstanding rights, existing or renewed mineral leases, road realignment needed to prevent resource damage or address safety hazards, and certain stewardship purposes. (Draft EIS Volume I, pp. 13–14.)
Alternative 2: Full rescission
This is the administration’s proposed action.
The national Roadless Rule would be repealed, removing the nationwide prohibitions on road construction, road reconstruction, and timber harvest and removing the national Inventoried Roadless Area (IRA) designation from 44.7 million acres. Idaho and Colorado’s separate state-specific Roadless Rules would remain unchanged. (Draft EIS Volume I, p. 15.)
The Forest Service makes clear that rescission itself would not immediately authorize a specific road or timber sale. Future projects would still be governed by land management plans and other applicable laws and regulations. (Draft EIS Volume I, p. 15.)
At the same time, the agency’s analysis says an increase in road construction, road reconstruction, and timber harvest under Alternative 2 is “reasonably foreseeable.” (Draft EIS Volume I, p. 140.)
Alternative 3: Modified Roadless Rule
The third alternative would keep protections on some roadless areas while removing them from others.
Under Alternative 3, Roadless Rule prohibitions and designation would be removed from approximately 31.7 million acres while current protections would continue on approximately 13 million acres. (Draft EIS Volume I, pp. 15–17.)
Among other things, this alternative would remove protections from roadless areas within certain wildland-urban interface areas and within one-half mile of existing roads. The DEIS says 17.9 million acres fall into those categories, along with additional acreage in the Tongass and areas that are already congressionally designated or no longer National Forest land. (Draft EIS Volume I, pp. 16–17.)
How you can take action to protect the Roadless Rule
The most important thing you can do is submit a public comment before September 21, 2026. You can do that through Regulations.gov under docket FS-2025-0001.
There are some tools to help you leave a substantive comment:
Public comment guide: https://roadless.org/roadless-comments
Maps & more comment help: https://morethanjustparks.com/roadless-rule/
What is a “substantive” comment?
I know that word makes federal public comment sound way more intimidating than it actually is. And there’s a lot of misinformation floating about online about what “counts” as a comment versus not.
✅ Unique substantive comments matter more than copy/paste identical comments often submitted through third-party forms and petitions (identical comments are counted as one submission).
✅ Identical comments do still matter, but they’re not as strong or effective. Even though unique comments are preferred and counted separately, the USDA will still count up and report all individual comments as well, even the identical ones. They are just considered duplicative and not as effective. According to this paper by George Washington University, the total number of comments receieved matter, but the agencies care more about unique comments and cannot take action based on sheer volume.
✅ Unique substantive comments matter more than unique non-substantive comments. In other words, don’t use your comment to insult Brooke Rollins or Trump (I mean, you can; it just won’t be as effective in moving the needle).
✅ You can submit as many comments as you’d like, but they do need to be unique.
How to write a substantive comment
A substantive comment gives the agency something specific to consider. It can point to a piece of the analysis you disagree with, a conclusion you think is unsupported, an impact you think was minimized, a piece of research you think should be considered, or a personal experience that adds relevant information to the record. You can even upload photos, documents, and research.
The DEIS itself defines substantive comments as information that “meaningfully informs” consideration of reasonably foreseeable impacts. (Draft EIS Volume I, Appendix 3, p. 296.)
It does not need to be long.
For example, you could write something along the lines of:
I oppose Alternative 2 and support Alternative 1. On pages 89–90 of the Draft EIS, the Forest Service reports much higher rates of human-caused wildfire ignitions on other National Forest lands than in affected roadless areas and states that human-caused ignitions increase with proximity to roads. I am concerned that removing nationwide road-building restrictions could increase human-caused ignition risk. I would like USDA to more clearly explain how this evidence supports its rationale for rescission.
That identifies a specific part of the analysis, explains the concern, and asks the agency to address it. And if all you have the bandwidth to do is submit a short comment or use an organizational action tool, please still participate. Every comment can still help demonstrate public opposition and build the record, even though more specific comments are more useful.
Public comment talking points
Here are some specific things you can comment on in the DEIS. You do not need to cover all of these. Pick one or two issues you actually care about and write about those in your own words. Or if you feel so inspired, make a unique comment for each issue.
Please do not copy and paste this blog post into Regulations.gov.
Wildfire
Wildfire has been one of the main arguments used to justify rescinding the Roadless Rule, but the agency’s own analysis makes that argument a lot more complicated.
The DEIS reports human-caused ignition density of 22.4 fires per million acres per year on other National Forest lands, compared with 3.0 in potentially affected roadless areas and 2.7 in wilderness areas. (Draft EIS Volume I, p. 90, Table 21.)
On the previous page, the agency says overall ignition density is approximately four times greater on other National Forest lands than in potentially affected roadless areas and Wilderness, with most of that difference coming from human-caused ignitions. It also reports that, among fires with known causes, 57% of fires on other National Forest lands were human-caused, compared with roadless areas where 74% were naturally ignited. (Draft EIS Volume I, p. 89.)
The agency then states that human-caused ignitions increase with proximity to roads, supporting the idea that roads facilitate human access and can therefore result in more human-caused fires. (Draft EIS Volume I, p. 90.)
Roads are obviously not the only factor involved in wildfire behavior, and roadless areas can absolutely burn. The DEIS itself discusses some of that nuance. But I think it is completely reasonable to ask the USDA to better explain how removing road-building restrictions supports its wildfire rationale when its own analysis shows such a substantial difference in human-caused ignition rates.
Wildlife and biodiversity
The biodiversity section is another place where their own analysis gives us a lot to respond to.
The DEIS concludes that road construction, road reconstruction, and timber harvest can have long-term adverse effects on biodiversity through habitat fragmentation, loss of connectivity, negative edge effects, and human disturbance. It says these impacts would likely be more frequent and broader in scale under Alternative 2 and least under Alternative 1. (Draft EIS Volume I, p. 157.)
Under Alternative 2 specifically, the Forest Service identifies potential adverse impacts including habitat loss and degradation, fragmentation, lost connectivity, barriers to movement and migration, and increased human disturbance. (Draft EIS Volume I, p. 158.)
Its preliminary biological assessments also reached “may affect, likely to adversely affect” determinations for 327 ESA-listed species and 71 designated critical habitats under Alternative 2. (Draft EIS Volume I, p. 161; repeated in the conclusion on p. 162.)
A strong comment here could ask why USDA is proposing the alternative with the greatest potential biodiversity impacts when Alternative 1 remains available.
Drinking water and watersheds
According to the Forest Service’s Forest to Faucets analysis, there are more than 7,000 municipal water intakes within watersheds containing potentially affected roadless areas. The agency estimates that approximately 24 million people outside Alaska use water originating within potentially affected IRAs. (Draft EIS Volume I, p. 121, Table 35.)
The DEIS also notes that nearly 5 million people in the Pacific Southwest receive drinking water from municipal intakes within watersheds containing potentially affected roadless areas. (Draft EIS Volume I, p. 121.)
For me, this is one of the clearest examples of why the Roadless Rule matters even to people who may never visit or recreate in one of these places. National Forests are watersheds, and what happens upstream matters downstream.
A comment could ask the USDA to more fully account for the long-term risks to watersheds associated with additional road construction and timber harvest, particularly given how many municipal water systems rely on water originating in these landscapes.
Road maintenance and taxpayer cost
The Forest Service already manages a massive road system and is already struggling to maintain it. According to the DEIS, annual appropriations for Forest Service road construction, improvement, and maintenance peaked at $234 million in 2004 and fell to $73 million in 2024. The agency describes that as a decline of almost 70% over 20 years. (Draft EIS Volume I, p. 43, Figure 6.)
The agency also estimates a $6.9 billion deferred-maintenance backlog for roads and bridges in 2024. That estimate only includes passenger-car roads at maintenance levels 3 through 5 and excludes lower-maintenance roads because the Forest Service does not currently track deferred maintenance for them nationally. (Draft EIS Volume I, p. 43.)
That makes the fiscal argument around building more roads worth questioning. Why on earth should taxpayers take on more road infrastructure when the Forest Service already has billions of dollars in deferred maintenance on the system it has now?
Recreation and access
This is going to be the thing you see conservative organizations like the American Conservation Coalition or Blue Ribbon Coalition hone in on. They will wax poetic about how they want to expand recreation access. But they're woefully misguided. So, let's dig into this a bit more.
The DEIS acknowledges that Alternative 2 could create some additional road-based recreation opportunities. But the DEIS also says that Alternative 2 has the greatest potential impact on recreation settings and scenery. It says timber harvest and road construction could create noise, visible infrastructure, and temporary closures, while long-term changes could shift recreation areas toward more developed conditions. It estimates approximately 12 million more non-motorized acres could be affected under Alternative 2 than Alternative 3. (Draft EIS Volume I, p. 192.)
The summary section also says that, although some permanent roads could eventually support trailheads or primitive campsites, most new roads would likely be temporary and closed to public motor vehicle use. The DEIS says expanded road-based recreation could come with reduced opportunities for quiet, remote, and self-reliant recreation and increased user conflicts. (Draft EIS Volume I, p. 25.)
That matters when rescission gets framed as an “access” issue. Rescinding the Roadless Rule is not opening up our forests for more recreation access. No. It’s also not helping disabled people have more access.
I wrote more about this during the last comment period, especially when it comes to disability access, because actual accessibility takes planning and investment. A temporary logging road closed to public motor vehicles does not automatically make public lands meaningfully more accessible.
Tribal rights and Tribal opposition
To nobody’s surprise, the Tribal section of the DEIS deserves a lot more attention than it has received. But what else is new. I’m shocked there even was a section about this considering how often Indigenous voices are silenced, to be frank.
The USDA reports 64 requests for consultation, with 29 consultations held and another five scheduled at the time the DEIS was prepared. (Draft EIS Volume I, p. 9.)
Later in the DEIS, they describe “clear and consistent strong opposition” to Roadless Rule rescission, with few exceptions, based on Tribal responses, consultation requests, and consultation documentation. (Draft EIS Volume I, p. 198.)
The USDA also acknowledges that additional timber harvest and road construction under Alternatives 2 and 3 are reasonably foreseeable and could have long-term negative effects on Tribal rights and interests. (Draft EIS Volume I, p. 201.)
The DEIS specifically says new road infrastructure may lead to unauthorized public access, vandalism, or desecration of sacred sites and traditional cultural places, and discusses potential impacts to areas used for ceremony, prayer, solitude, hunting, fishing, gathering, and other treaty-reserved or culturally important activities. (Draft EIS Volume I, pp. 201–202.)
A public comment could ask how USDA weighed that Tribal opposition, along with treaty rights, sacred sites, cultural resources, and federal trust responsibilities, when choosing full rescission as its proposed action.
The alternatives analysis
Another thing worth asking about is how the USDA decided which alternatives were worth studying in detail. The DEIS discusses several other alternatives that had previously been analyzed for the Tongass National Forest. It says Alternatives 2 through 5 from the 2020 Alaska Roadless Rule analysis were reconsidered but rejected because they “would not comply with the policy direction in Executive Order 14153.” (Draft EIS Volume I, p. 29.)
That raises a fair question about how much room the agency really had to consider alternatives that maintained stronger protections.
If you are concerned that administration policy narrowed the range of options the Forest Service was willing to seriously consider, this is one place to focus your comment.
How to write your comment
You can keep this very simple. It doesn’t need to be an essay. In fact, if you find yourself a bit more on the verbose side of things (like myself), you can split up your longer comment into separate ones on each topic.
Start by introducing yourself and explaining why this issue matters to you. You might live near a National Forest, recreate on public lands, care about wildlife, depend on clean water, work in the outdoor economy, or simply believe intact public lands are worth protecting.
Then state your position clearly. I recommend specifically saying that you oppose Alternative 2 and support Alternative 1, the No Action Alternative.
After that, choose one or two specific findings from the DEIS and explain why they concern you. Include the page number if you can. That makes it especially easy for the agency to understand exactly what part of its analysis you are responding to.
Personal experience can be useful here too when it is relevant. You can upload photos, documents, and link to data/resources as well. You can finish by asking the agency to address your concern and choose Alternative 1.
And that is enough! Easy, peasy.
Tools available to help you
The DEIS is huge, but you do not need to read it cover to cover. Volume I of the DEIS is broken out by topic. The environmental analysis includes roads, vegetation and forest management, fire and fuels, invasive species, soil and water, biodiversity, recreation and scenery, cultural resources, Tribal rights and interests, and social and economic impacts. Volume II contains state maps of the affected roadless areas.
It’s a lot, so start with the topic you actually care about and go from there.
There are also organizations putting together interactive maps, comment tools, species resources, recreation data, and other information. I’ll keep adding useful tools here as they come out.
Use those resources to better understand the issue and help build your own comment in your own words.
Public comment guide: https://roadless.org/roadless-comments
Maps & more comment help: https://morethanjustparks.com/roadless-rule/
Background: What is the Roadless Rule?
The Roadless Area Conservation Rule was adopted in 2001 and generally restricts road construction, road reconstruction, and timber harvesting within designated Inventoried Roadless Areas on National Forest land, with limited exceptions.
Roadless areas are still public lands, and the rule does not prohibit all activity in them. The DEIS specifically notes that activities that do not require new road construction can still occur, including certain timber harvest, development of valid mineral claims, grazing, and permitted off-highway vehicle use. Forest health work can also occur where access is available without constructing prohibited roads.
People hike, hunt, fish, bike, climb, paddle, camp, gather, and exercise treaty rights in roadless areas.
There are currently approximately 58.2 million acres of inventoried roadless areas across the National Forests, representing about 30% of National Forest land. The 2001 national Roadless Rule currently applies to approximately 44.7 million acres, including roughly 9.3 million acres in the Tongass National Forest. Some areas are going to be exempt from this, though: About 9 million acres in Idaho and 4 million acres in Colorado are instead governed by those states’ separate roadless rules. That is why you may see different acreage numbers depending on the source.
Why was the Roadless Rule created?
The Roadless Rule has been one of the greatest conservation rulings in America. To put it simply: Roads have long-term consequences, and the DEIS itself documents many of them.
The Forest Service identifies potential effects from roads and timber harvest that include habitat fragmentation, lost connectivity, human disturbance, water-quality impacts, cultural impacts, and changes to recreation environments (noise pollution, etc).
There is also the financial reality of maintaining roads once they exist. The Forest Service reports a $6.9 billion road-and-bridge deferred maintenance backlog even before considering any additional roads that might someday be constructed.
The Roadless Rule created a national baseline for how some of the largest remaining relatively undeveloped areas in the National Forest are managed. Those protections have now been in place for more than two decades. We need them to stay.
How this fits into the bigger picture
I don’t think the Roadless Rule rescission makes sense when you look at it by itself, and I definitely don’t think it makes sense to talk about it as some isolated debate over roads.
This proposal is part of a much larger push by the Trump administration to increase logging, mining, energy development, and other forms of resource extraction from public lands. It’s pretty crystal clear what they’re trying to do here.
The DEIS itself makes that connection, which is both equally frustrating and validating.
When discussing alternatives that were considered but rejected for the Tongass, the Forest Service says they would not meet the purpose and need of the current rulemaking because they would not comply with the policy direction in Executive Order 14153, Trump’s order focused on expanding resource development in Alaska. That context matters.
We are watching an administration repeatedly look at protected public lands and ask what more can be taken from them. More timber. More minerals. More energy. More roads. More development. And I think that is a fundamentally backwards way to think about public lands.
A forest protecting drinking water matters. A migration corridor matters. A salmon stream matters. Sacred places matter. A quiet backcountry landscape matters. A place you will never personally visit still matters.
We do not need to prove that every acre can generate revenue before deciding it is worth protecting.
And people have already made their feelings about this particular proposal pretty clear. During this administration’s first Roadless Rule comment period, approximately 99% of the comment letters opposed rescission. (Draft EIS Volume I, p. 9.)
The administration moved forward anyway.
That does not make this comment period pointless, though. Please don’t be disheartened. I think what it does is that it makes the record even more important. It’s another data point to say: This admin doesn’t listen, doesn’t care, and only worries about their own motives (rather than the best interests of the American people).
So, I ask you: Please submit a comment. The USDA has to consider public input. Submit one because substantive comments become part of the administrative record. Submit one because that record can matter later if the final rule is challenged. Submit one because lawmakers, journalists, advocates, and the broader public need to see how much opposition exists.
And mostly, submit one because these places are worth fighting for.
Comments close September 21, 2026. Tell USDA to reject Alternative 2 and choose Alternative 1. Keep the Roadless Rule.
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